Know Your Customer & Anti-Money Laundering Measures Policy

Policy ID: PCI/POL/02/2026-27 • Version 1.0 Owner: Principal Officer / Designated Director • Approver: Board of Directors Sources: KYC • Review: Annual / regulatory change

Purpose and application

Customer-facing NBFC activities; apply PMLA duties and category-specific exemptions as verified.

1. Customer acceptance: - No anonymous, fictitious or prohibited relationship shall be opened. Identify the customer, authorized signatory and beneficial owner; verify OVD, PAN/Form 60 as applicable, legal constitution and purpose before disbursement. Aadhaar shall be used only through legally permitted methods.

2. Risk classification: - Assign low, medium or high ML/TF risk using occupation, geography, product, ownership and transaction pattern. Apply enhanced checks and authorized senior approval for PEPs and other higher-risk relationships. Conduct sanctions screening and statutory freezing/reporting procedures.

3. Ongoing monitoring: - Monitor unusual cash, third-party repayments, rapid turnover and inconsistent income. Escalate alerts to the Principal Officer without tipping off customers. A suspicious transaction report shall not depend on the amount or on completion of a transaction.

4. Updating and reporting: - Use the prescribed CKYCR upload/update process and communicate the KYC identifier. Follow current periodic updating rules, customer notices and low-risk relief provisions. File applicable FIU reports within statutory deadlines; keep proof of submission and confidential STR access.

5. Retention and control: - Retain transaction records for at least five years from the transaction and identification records for at least five years after relationship closure, subject to longer legal holds. Train staff and independently test KYC controls annually.

6. Cash-income documentation: - As a Company underwriting control, cash-income customers shall sign an income declaration with the Branch Manager’s verification/signature. Independently corroborate income and capacity; this declaration is not an OVD, KYC substitute or proof that prevents AML escalation. Source codes are linked to the Reference Register. Read with the common implementation controls and relevant annexes. Applicable law and RBI Directions prevail.